Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Customs valuation and classification require comparable evidence and assessment of imported goods in their actual condition, invalidating related pena...
Penalty under section 271D for alleged contravention of section 269SS was found unsustainable where the assessment proceedings did not record any finding of such violation. The Tribunal noted that the assessee had furnished complete details of the cash deposits during assessment, and that penalty could not rest on a later second opinion. It also referred to the view in Sahara India Financial Corporation Ltd. that cash deposits by a non-banking financial company dealing with depositors in rural areas without adequate banking facilities did not attract penalty in the stated circumstances. On that basis, the penalty was deleted.
Penalty under section 271D for alleged contravention of section 269SS was found unsustainable where the assessment proceedings did not record any finding of such violation. The Tribunal noted that the assessee had furnished complete details of the cash deposits during assessment, and that penalty could not rest on a later second opinion. It also referred to the view in Sahara India Financial Corporation Ltd. that cash deposits by a non-banking financial company dealing with depositors in rural areas without adequate banking facilities did not attract penalty in the stated circumstances. On that basis, the penalty was deleted.
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